This Cookie Policy describes the cookies and other data collection technologies that Orion Advisor Solutions, Inc. and its parents, subsidiaries, and affiliates, including but not limited to, Orion Advisor Technology, LLC, Orion Portfolio Solutions, LLC (d/b/a Orion Wealth Management, Brinker Capital Investments, and Brinker Capital), Constellation Trust Company, Advizr, Inc. (d/b/a Orion Planning), Brinker Capital Securities, LLC, GxWorks, LLC (d/b/a Orion Risk Intelligence), Redtail Technology, Inc., Townsquare Capital, LLC (d/b/a Orion OCIO), and BasisCode Compliance LLC (d/b/a Orion Compliance) (collectively, “Orion” or “we” or “us” or “our”) utilizes when you (“user”) visit our website (“Site”). This Cookie Policy provides detailed information about how and when we use cookies and is part of and incorporated into our Privacy Policy available at https://orion.com/download/privacy-policy/. Orion places cookies and other data collection technologies on your device. Orion will treat any Personal Information collected through our use of cookies and other data collection technology in accordance with the Privacy Policy.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive by the websites you visit. A cookie typically contains the name of the internet domain from which the cookie originated, the expiration date of the cookie, and a randomly generated unique number or similar identifier. Usage of our Site might include the time at which your device accesses our Site, the page you visit, how long you spend on each page, and the links you click.  Cookies might also collect the link that brought you to our Site and webpage you visit after you leave our Site. A cookie also may contain information about your computer, such as user settings, browsing history and Internet activities. If you make multiple visits to our Site, cookies allow our Site to recognize your browser.

Most browsers are set to accept cookies by default, but you can control and manage the use of cookies on your browser or device by deleting them from your browser history when you leave our Site. If you do not wish to receive cookies, you may set your browser to reject cookies or alert you when a cookie is dropped on your computer. If you use a device to access our Site, your device identification may be collected and used for purposes similar to other cookies. Most mobile devices allow you to disable the ability for geolocation information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geolocation information. Please be advised, if you disable certain cookies, some of the features of our Site may not function properly or be available to you, such as those which require identification.

Cookies can be categorized by how long they remain on your device. All cookies have expiration dates in them that determine how long they stay in your browser. There are two broad categories of duration:

Session Cookies. Session cookies are temporary cookies that exist only during an online session and are not stored on your computer or mobile device. Session cookies are used as part of the login, authentication and session management flows of the platform websites and to process your online transactions and requests. Certain session cookies are also used to understand, for example, if a user interacting with our company Site is a new visitor or a visitor returning as part of the same browsing session. Session cookies remain on your device until you close your browser when they are automatically deleted.

Persistent Cookies. Persistent cookies are those placed on your computer or mobile device for a pre-determined length of time when you visit our Site. We use persistent cookies that only the Site can read and use, to identify the fact that you are a customer or Site visitor, to understand which areas of our Sites and platform are most popular, and to store customer and user preference data. Persistent cookies remain on your device until deleted manually or automatically.

To learn more about cookies, web beacons, and other data collection technology, visit www.allaboutcookies.org. Please note that the data collection technologies we use may change from time to time.

User tokens are pieces of data that act as a digitally encoded signature of the user, which allows us to verify and authenticate the identity of the user.  Like cookies and other types of tracking technologies, user tokens are stored locally on a user’s device.

Web beacons are small graphic images and may be embedded in web pages and email messages. Web beacons may be used to monitor the number of visitors to a website, to track how users navigate a website, or to count how many emails were actually opened or specific pages or links were actually viewed.

HOW WE USE COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

Orion utilizes cookies and user tokens to help us keep our Site secure, measure the performance of our Site, understand how visitors interact with the Site, and count the number of visitors to the Site. Cookies help us understand how our Site is being used and improve your user experience. Orion may also use cookies or other electronic tools to collect and compile statistical and other information about your use of the services provided on this Site. Cookies help us understand how the site is being used and improve your experience. We use both first-party cookies and third-party cookies. First-party cookies are cookies placed on your device by the Site.  Third-party cookies are cookies placed by another website when you visit the Site.

Orion has relationships with third-party advertising companies to place advertisements on this Site and other websites, and to perform data collection and reporting functions for the Site. These third-party advertising companies may place advertising cookies on your computer when you visit our Site or other websites so that they can display targeted advertisements to you. When you view or interact with a displayed advertisement, these third-party advertising companies may collect your Personal Information. Also, cookies placed by third parties collect usage data about the use of the Site and provide services, such as remembering that you logged into your account or the location you selected as your preferred location. We use cookies provided by third-party service providers to assist us in better understanding our visitors.  Orion uses that information to offer better Site experiences and tools in the future.

Orion utilizes the information collected by web beacons to statistically monitor how many people are using our Site. Web beacons are small graphic images that may be embedded in web pages and email messages. Web beacons may be used to monitor the number of visitors to a website, to track how users navigate a website, or to count how many emails were actually opened or specific pages or links were actually viewed.

YOUR CHOICES REGARDING THE USE OF COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

At any time, users may control how we use cookies via their browser’s security settings. You can manage your individual preferences with respect to each category of cookies that you agree to accept from our websites. You may update or change your cookie preferences at any time. Orion will act on your most recent choice.

To update your preferences for the cookies you accept from our Site at any time, please click “Cookie Settings” in the footer of the Site.

If you “Accept all,” you are consenting to Orion’s collection and use of your data collected by all of the cookies used on the Site. By consenting or “opting in” to each of these cookies, you are consenting to Orion’s collection, use, and sharing of your information through cookies. Please note that our cookies options and tools vary by region and country in accordance with applicable law. For websites directed to countries with these rights, we obtain consent from users for cookies and offers choices regarding cookie collection. For example, in the European Economic Area, users have the right to reject the installation of all but essential cookies on their devices.  Users may withdraw consent at any time by changing settings. Please be advised that if you disable certain cookies, some of the features of our Site may not function properly or be available to you, such as those which require identification, and refusing all or certain cookies may result in a more limited experience of some of the services offered on the Site.

Most browsers are set to accept cookies by default, but you can control and manage the use of cookies on your browser or device by deleting them from your browser history when you leave our Site. If you do not wish to receive cookies, you may set your browser to reject cookies or alert you when a cookie is dropped on your computer. These controls vary by browser, and manufacturers may change both the settings they make available and how they work at any time. Certain parts of the Site may not work properly if you have disabled browser cookie use. If you use a device to access our Site, your device identification may be collected and used for purposes similar to other cookies.

In addition, our systems are configured to detect and respond to the Global Privacy Control (“GPC”). The GPC is a method for individuals to opt-out of the sale or sharing of their personal information, as such terms are described under applicable data protection laws, via a user-enabled privacy control that is available on certain internet browsers. You can learn more about the GPC here.

A summary of the types of cookies that may be used when you visit the Site can be accessed and reviewed at the “Cookie Settings” link in the footer of the Site. As stated above, you can also update your preferences with respect to those cookies at that link.

1906-OAS-7/31/2024